Case Document Entered on FLSD Docket Page of Herman Mermelstein UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CV-80232-MARRA.JOHNSON JANE DOE NO Plaintiff JEFFREY EPSTEIN Defendant PLAINTIFF JANE DOE ANSWERS TO DEFENDANTS FIRST INTERROGATORIES Plaintiff JANE DOE by and through their undersigned counsel and pursuant to Federal Rules of Civil Procedure Rule hereby responds to Defendant JEFFREY EPSTEINS First Set of Interrogatories to Plaintiff as follows General Objections Plaintiff objects to Defendants Interrogatories to the extent that the Interrogatories call for the disclosure of information protected by the attorney-client privilege attorney work-product doctrine or other applicable privilege or immunity whether created by statute or common law Plaintiff claims such privileges and protections to the extent implicated by each Interrogatory and excludes privileged and rotect information from any responses to Defendants discovery Any disclosure is inadvertent and Is not intended to waive those privileges or protections which are specifically reserved Plaintiff objects to Defendants Interrogatories to the extent that same are vague ambiguous incomprehensible and/or overly broad Case Document Entered on FLSD Docket Page of Herman Mermelstein Doe No Epstein Page8 No p.m Lb-U I-Luu Describe each injury physical emotional mental for which you are claiming damages in this case specifying the part of your body that was injured the nature of the injury and as to any injuries you contend are permanent the effects on you that you claim are permanent Answer Plaintiff has suffered severe psychological emotional and psychical injuries including without limitation anxiety depression suicidal ideation guilt self blame feelings of being degraded feeling unattractive diminished sense of feminity fluctuations in weight/appetite sexual/intimacy problems flashbacks disturbing memories stress irritability feelings of being isolated and trapped diminished trust social problems problems in personal relationships indecisiveness lower energy lower ambition and initiative headaches back pain feels stress particularly around men obsessive thoughts problems concentrating alcohol abuse corruption of morals and values loss of innocence and cries alot Plaintiffs psychological and emotional injuries will be analyzed and explained by a forensic expert whose opinions and related information will be disclosed in accordance with the expert discovery rules of the Federal Rules of Civil Procedure Plaintiff reserves the right to supplement this response in accordance with the Federal Rules of Civil Procedure Please state each item of damage that you claim and include in your answer the count to which the item of damages relates the factual basis for each item of damages and an explanation of how you computed each item of damages including any mathematical formula used Answer Plaintiff objects to this interrogatory as calling for an expert opinion and calculation Subject to said objection Plaintiff states that she seeks damages arising from her psychological and emotional injuries These damages include pain and suffering costs of psychological care and treatment and loss of earning capacity The pecuniary elements of these damages will be analyzed and computed by an appropriate expert Discovery is ongoing and will be supplemented in accordance with the Federal Rules of Civil Procedure t.J..J Case Document Entered on FLSD Docket Page of Herman Mermelstein Doe No Epstein Page p.m Plaintiff was paid for bringin Please list each time you were interviewed by any state or federal law enforcement agent or prosecutor who was present whether notes were taken and what you recall saying to them Answer See Plaintiffs Answer to Interrogatory No Please describe any statements made to you by any federal or state law enforcement agent or prosecutor regarding the availability of civil remedies against Mr Epstein and regarding whether there would be any benefit from your voluntary cooperation with law enforcement Answer Plaintiff received correspondence in July and September from A.U.S.A A care of the undersigned attorney No statements were ever ooperation in the criminal case would benefit a civil claim January Respectfully submitted HERMAN MERMELSTEIN P.A Biscayne Blvd Suite Miami Florida w.hermanlaw.com Tel f!!Jit Jeffrey Herman jherman hermanlaw.com Florida Bar No Stuart Mermelstein smermelstein hermanlaw.com Florida Bar No Adam Horowitz ahorowitz hermanlaw.com Case Document Entered on FLSD Docket Page of Herman Mermelsteln p.m VERIFICATION being duly sworn deposes and says that the for swers to interrogatories are w.i.e and corre to the best of her knowledge information and belief I STATE OF FLORIDA ss COUNTY OF PALM BEACH BSCRIBED before me this day ot:knuC/1 lj by who is personally known to me or has produced the ng i einti cation I A_ which is current or has been issued within the past five years and bears a serial or other identifying number EZ ialod-h ee Print Name aP Hi NOTARY PUBLIC STATE OF FLORIDA Commission Number My commission expires Notarial Seal Notaty Public Slaw offlorida Ellzabettl Gulienez MyCommi slon OD Expires Case Document Entered on FLSD Docket Page of Herman Mermelstein Doe No Epstein Page p.m Certificate of Service WE HEREBY CERTIFY that a true copy of the foregoing has been sent via U.S Mail and facsimile to the following addressees this day of January Robert Critton Jr Esq Burman Critton Luttier Coleman Flagler Drive Suite West Palm Beach FL Phone Fax rcrit bclclaw.com Co-Counsel for Defendant Jeffrey Epstein Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax jagesg bellsouth.net Jo-Counsel for Defendant Jeffrey Epstein Michael Tein Esq Lewis Tein P.L Grand Avenue Suite Coconut Grove FL Fax Co-Counsel for Defendant Jeffrey Epstein tein lewistein.com I
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